Reg Z and Courier Fees Answer by Lucy Griffin and Jim Bedsole, BOL Gurus
Question: In regards to Reg Z and Sec. 32. Is a courier fee "always" a Sec. 32 charge?
Answer by Lucy Griffin: BIO AND CONTACT INFO
It is always a finance charge (unless you can prove that the borrower requested the service and you wouldn't have used it otherwise.) Because it is always a finance charge, it is always in the Section 32 calculations.
Answer by Jim Bedsole: BIO AND CONTACT INFO
One exception to this would be if the courier fee was being charged by a third-party closing agent. In this case, the courier fee would only be considered a finance charge (and thus included in Section 32 points and fees calculations) if the creditor required the use of the courier or retained any portion of the courier fee charged. See Reg Z Staff Commentary Section 226.4(a)(2).
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